Strategic responses to sustainability certification under regulatory uncertainty: a real-options perspective

Forthcoming EU sustainability regulation (the adopted Empowering Consumers for the Green Transition Directive and the European Commission’s proposal for a Green Claims Directive) requires that environmental claims made in the European market be substantiated through third-party verification. While intended to curb greenwashing and enhance consumer trust, these measures risk widening existing inequities in access to sustainability certification. This study examines how the strategic options available to hotels are reshaped by this emerging regulatory landscape. Using Real Options Theory as the analytical framework, we combine a large-scale dataset of 82,047 European hotels listed on Booking.com with expert interviews to assess how resource endowments, value-chain structures and platform governance shape certification uptake. Results show that hotels with greater financial capacity, international brand affiliation and larger room inventories are substantially more likely to obtain third-party certification. By contrast, smaller independent hotels face proportionally higher verification costs, limited access to recognised schemes and the loss of low-cost signalling pathways. The study concludes that regulatory tightening affects not only the costs and benefits of certification, but also the distribution of feasible strategic options, with implications for market access, equity and the credibility of sustainability communication.